Battery Sorting & Handling Work Instructions

Battery Packaging & Shipping Document #:

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VERIFY CURRENT VERSION ON WEB SITE MASTER LIST PRIOR TO USE – UNCONTROLLED WHEN PRINTED

1.0 Purpose & Scope 1.1 This document prescribes methods and practices for the safe handling and management of universal waste batteries, including lead acid, nickel, alkaline, and mercury based batteries handled at any AERC facility. This procedure is intended to provide baseline safe work operating procedures in the management of such devices. Employees must recognize the need to employ sound judgment and responsible practices to ensure their personal safety as well as the safety of their co-workers and the community in which AERC operates. Additional information on Battery Handling, Packaging, and Shipping is available from the AERC Regulatory Affairs Department upon request.

2.0 Prerequisite Tools and Personal Protective Equipment 2.1 Work Uniform or Cover Up 2.2 Steel Toe Boots 2.3 Safety Glasses 2.4 Nitrile Gloves 2.5 Lifting belt (optional) 2.6 Splash Goggles and Splash Apron when working with Unsealed Wet Lead Acid

batteries 2.7 Other PPE may be required as necessary for leaking batteries

3.0 Instructions 3.1 Battery Danger Signs

3.1.1 Danger: If batteries are hot or smoking, get your supervisor. Do not attempt to separate batteries from each other.

3.1.2 Danger: A battery container is leaking or bulged get your supervisor immediately. Do not attempt to open container until advised what to do by your supervisor.

3.1.3 Danger: A battery may never be thrown onto the floor to identify the battery inside. Batteries may not be dropped, hit or broken in any way. No battery may be taken apart with tools or by hand to identify the battery. Battery packs will not be taken apart so they fit into a container. Batteries may not be opened in any way.

3.2 Spill Response work instructions are available in CP-008-W3 Leaking Lead Acid Battery Spill Response.

3.3 Quality Control of Incoming Batteries 3.3.1 Before removing batteries from truck, look for containers that may be

leaking or bulging. Danger: If you find a container that is bulging or leaking, STOP! Notify your supervisor immediately!

3.3.2 Remove pallets of batteries with a forklift or pallet jack.


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3.3.3 All drums that are floor-loaded should be removed by using a drum dolly or drum grabber (drum grabber for metal drums only).

3.3.4 Lithium batteries must be QC’d and moved to the battery staging area first.

3.3.5 Danger: All containers that have lids must be vented. Do not remove bungs or rings to vent container. Always use punch with a brass or beryllium tip. Static or sparking may occur when removing bungs and/or lids. This can cause an explosion if batteries are leaking or reacting.

3.4 Sorting & Packaging 3.4.1 Lithium based batteries must be processed first due to the higher risk of

fire. 3.4.2 Batteries must be separated not only by AERC category, but by type

within each category. 3.4.3 Never mix batteries of different categories together in the same

container. 3.4.4 Use the OP-011 Source Control Procedure and OP-011-F1 to report and

manage any type or quantity discrepancies between batteries listed on the BOL and those received or processed.

3.4.5 Incident reporting is required by law for ALL incidents of fire, violent

rupture, explosion, or a dangerous evolution of heat which occur as a

direct result of a battery or battery-powered device. Dangerous

evolution of heat is defined as an amount of heat sufficient to be dangerous to packaging or personal safety to include charring of packaging, melting of packaging, scorching of packaging or other evidence. Notify the Regulatory Affairs department upon any incident in question.

3.4.6 Each page that follows has instructions for the packaging and labeling of each type of battery in accordance with RCRA and DOT regulations. Each page represents the instructions for one type of battery (with a few that expand to two pages).

3.4.7 If you are unsure of the battery type or have questions on the appropriate handling, seek guidance from your supervisor. The Health & Safety Coordinator may also be contacted according to the information posted in your facility.


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Category Battery Type Packaging Labeling

1

Wet-Cell Lead Acid

[Flooded lead acid batteries of various sizes used in industrial, automotive and standby power

(UPS) applications.]

Fully cover each terminal with electrical tape or similar non-

conductive material.

Package SMALL (< 3” x 5” X 6”) batteries in one of the following

DOT specification packages.

1H2 – Plastic, removable head drum; or

1G2 – Fiberboard drum with poly liner (4 mil thickness); or

CF – Fiber box with poly liner (4 mil thickness).

Metal drums (1A2) are not acceptable for shipping of wet cell batteries. PG III performance level spec packaging required.

Vented pressure relief bungs are required for containers > 5-gallon capacity to avoid potentially dangerous overpressure.

Close and seal container with appropriate lid.

Package LARGE, non-leaking lead acid batteries using one of the

following methods:

1. Place batteries securely on a wooden pallet. Use shrink-wrap or nylon strapping to secure batteries to the pallet. DO NOT USE METAL STRAPPING TO SECURE BATTERIES TO THE PALLET. Batteries may be double stacked on pallets, but pallet height may not exceed 2 times the height of the battery.

2. Individual, large lead acid batteries may be packaged one battery per pallet, poly 5-gallon pail or fiberboard box.

Apply Universal Waste and Corrosive

Labels to each pail, drum and/or pallet.

Ship on a standard BOL using the

description

UN2794, Batteries,

wet, filled with acid, 8,

III (Used lead acid

batteries for

recycling)(ERG #154)

Mark an in the HM Column


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1

Dry-Cell (Sealed) | Non-

spillable or Valve

Regulated Lead Acid

(VRLA)

[Non-Automotive/SLI batteries D-Size and larger used in

portable/rechargeable tools, emergency lighting and marine

applications.]











Package LARGE, non-leaking lead acid batteries using one of the

following methods:

1. Place batteries securely on a wooden pallet. Use shrink-wrap or nylon strapping to secure batteries to the pallet. DO NOT USE METAL STRAPPING TO SECURE BATTERIES TO THE PALLET. Batteries may be double stacked on pallets, but pallet height may not exceed 2 times the height of the battery.

2. Individual, large lead acid batteries may be packaged one battery per pallet, poly 5-gallon pail or fiberboard box.



Batteries must be contained in a strong outer packaging with the battery and outer packaging plainly identified with a durable marking stating “NONSPILLABLE” or “NONSPILLABLE BATTERY.”


description

UN2800, Batteries,

wet, non-spillable, 8, III

(Used lead acid

batteries for




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1

Leaking Lead Acid

Batteries

(Incidental Damaged)

Handle UW batteries having incidental damage as UW packaged in a separate 1H2 container (Plastic, removable head drum/pail).



If battery is badly damaged, place in a separate container or 4

mil poly bag.




description UN2794, Batteries, wet,

filled with acid, 8, III (Used/Damaged

lead acid batteries and battery acid

for recycling)(ERG #154)

Or –

UN2800, Batteries,

wet, non-spillable, 8, III

(Used/Damaged lead

acid batteries and

battery acid for




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Alkaline

[Dry - includes 1.5 & 9-volt]

Used in consumer devices (non-

rechargeable) with common sizes: A, AA, AAA, C, D, 9-volt, button &

coin.]

(EXCEPT IN THE STATE OF CALIFORNIA)

Batteries of this type (with the shipping description noted to the right) – DO NOT require protection from short circuiting. These batteries DO NOT need to be taped (insulated) from contact of terminals IF < 9-VOLTS capacity.

Dry-Cell, non-leaking Category 2 batteries (segregated from

leaking) in one of the following DOT specification packages. PG III performance level spec packaging required.

1A2 – Steel, removable head drum with a minimum 4-mil thickness poly liner; or


1G2 – Fiberboard drum with poly liner (4 mil thickness).



description

Batteries, dry, sealed,

n.o.s., (Used

alkaline/zinc-carbon

batteries for recycling)

CALIFORNIA ONLY:

Apply Universal Waste label to each pail, drum and/or pallet

instead of the Non-RCRA Regulated Waste Label.


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Zinc-carbon

[Dry | Non-Hg | 6-volt]

[Used in consumer devices (non-

rechargeable) with common sizes: A, AA, AAA, C, D, 9-volt | general

purpose & heavy duty.]










description


n.o.s., (Used

alkaline/zinc-carbon


CALIFORNIA ONLY:




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Alkaline [Wet]














description

UN2795, Batteries,

wet, filled with alkali,

8, III (Used Alkaline

batteries for




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NiFe

(Nickel Iron)














description

UN2795, Batteries,


8, III (Used NiFe

batteries for




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Zinc Air

[Sealed battery used consumer devices (as non-rechargeable)

commonly found as a button or coin cells.]

Fully cover each battery with electrical tape or place in a small

sealed plastic bag.












description

UN2795, Batteries,


8, III (Used Zinc Air

batteries for




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NiMH

(Nickel Metal Hydride)

[Used in consumer devices and

portable tools (rechargeable) with common sizes: AA, C, D, 9-volt &

flat box.]









Apply a Non-RCRA

Regulated Waste label

to each drum, pail, or

pallet.


description


n.o.s., (Used nickel-

metal hydride


CALIFORNIA ONLY:




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NiCd

(Nickel Cadmium)

[Dry-cell used in consumer devices and appliances (rechargeable) with common sizes: A, AA, AAA, C, D, 9-volt & flat box.]



NOTE: No taping need IF terminals are recessed within the

battery and can be packaged so that there is no hazard from short-circuiting







RCRA Regulated Universal Waste - These batteries

commonly fail TCLP for cadmium and consequently are regulated as Universal Waste.

Apply Universal Waste

label to each pail, drum

and/or pallet.


description

UN3028, Batteries, dry,

containing potassium

hydroxide solid, 8, III

(Used nickel-cadmium

batteries for



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NiCd [Wet]

[Wet-cell commonly used in

industrial applications such as back-up power.]











LARGE, non-leaking wet NiCd batteries (> 3” x 5” X 6”) must be

packaged using one of the following methods:

1. Place batteries securely on a wooden pallet. Place a piece of electrical tape over each terminal to avoid terminal contact. Use shrink-wrap or nylon strapping to secure batteries to the pallet. DO NOT USE METAL STRAPPING TO SECURE BATTERIES TO THE PALLET. Batteries may be double stacked on pallets, but pallet height may not exceed 1/1/2 times the width of the pallet.

2. Individual, large Category 2 batteries may be packaged one battery per pallet, poly 5-gallon pail or fiberboard box.




description

UN2795, Batteries,


8, III

(Used nickel-cadmium

batteries for




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Leaking or damaged

Category 2 Batteries

(Incidental Damaged)

Handle UW batteries having incidental damage as UW packaged in a separate 1H2 container (Plastic, removable head drum/pail).



Ship on BOL with other UW batteries under separate line item with the appropriate DOT name according to the battery type.

UN2795, Batteries, wet, filled with

alkali, 8, III (Used/damaged (fill-in)

batteries and electrolyte for


Or –

Batteries, dry, sealed, n.o.s.,

(Used/damaged (fill-in) batteries and

electrolyte for recycling)(ERG #154)

Or –

UN3028, Batteries, dry,

containing potassium

hydroxide solid, 8, III

(Used/damaged (fill-in)

batteries and

electrolyte for




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Mercury

Mercury Oxide

[Used in consumer devices (non-

rechargeable) with common sizes: AA, AAA, C, D & button cell.]


Packages which contain < 2 ½ pounds (estimated as

less than RQ) – shipping description as noted.

Non-leaking Category 3 batteries (segregated from leaking) in

one of the following DOT specification packages. PG III performance level spec packaging required.





Batteries must be contained in strong outer packaging.

.

Continued on Next Page

Apply Universal Waste Label to each pail,

drum and/or pallet.


description


n.o.s., (Used mercury-

containing batteries for

recycling)


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Packages which contain ≥ 2 ½ pounds (considered

greater than RQ)




description

RQ, UN2809, Mercury

contained in

manufactured articles,

8, III (Used mercury

batteries for




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Carbon Zinc (w/Hg)

[Used in consumer devices, e.g., flashlights and toys - non-

rechargeable.]


Packages which contain < 1 Lb Mercury are less

than the RQ – shipping description as noted.










drum and/or pallet.


description




recycling)


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Packages which contain > 1 Lb Mercury are

greater than the RQ – shipping description as

noted.




description

RQ, UN2809, Mercury

contained in



batteries for




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Silver Oxide (w/Hg)

(aka Silver-Zinc)

[Used in consumer devices such as

hearing aids, watches, cameras and calculators (non-

rechargeable) - common size: button cell.]


Packages which contain < 2 ½ pounds (estimated as

less than RQ) – shipping description as noted.








.



drum and/or pallet.


description




recycling)


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Packages which contain ≥ 2 ½ pounds (considered

greater than RQ) – shipping description as noted.




description

RQ, UN2809, Mercury

contained in



batteries for




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Silver Oxide

(aka Silver-Zinc)

[Used in consumer devices such as

hearing aids, watches, cameras and calculators (non-

rechargeable) - common size: button cell.]









.


drum and/or pallet.


description


n.o.s., (Used silver

oxide batteries for

recycling)


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3

ATON

“Aids to Navigation” batteries vary in construction and chemistry but commonly

contain zinc and mercury and an alkaline electrolyte (such as

sodium hydroxide).


sealed plastic bag.

Package batteries in one of the following DOT specification

packages.









description

Packages which contain < 2 ½ pounds

UN2795, Batteries, wet,

filled with alkali, 8, III

(Used ATON batteries

for recycling)(ERG #154)


Packages which contain ≥ 2 ½ pounds

RQ, UN2795, Batteries, wet, filled

with alkali, 8, III (Used ATON

batteries for recycling)(ERG #154)


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3 Damaged or Leaking

Category 3 Batteries

(Incidental Damage)


sealed plastic bag.

Package batteries in one of the following DOT specification

packages.








drum and/or pallet.

Apply Corrosive Label to each pail, drum

and/or pallet containing ATON batteries


appropriate description below. Add “RQ”

as a prefix where quantities are >= 2 ½

pounds.

RQ, UN2809, Mercury contained in

manufactured articles, 8, III

(Used/Damaged mercury-containing


Or –


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UN2795, Batteries, wet, filled with

alkali, 8, III (Used/damaged Mercury

Containing batteries)(ERG #154)

Or –

Batteries, dry, sealed, n.o.s.,

(Used/damaged Mercury Containing


Or –


n.o.s., (Used/damaged

silver oxide batteries for




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4

Lithium (Primary);

(Li | Manganese Dioxide | Li perchlorate within organic

solvent);

(Li | Thionyl Chloride | Li tetrachloroaluminate in

thionyl chloride).

FAILURE TO PROTECT TERMINALS WILL LEAD TO

OVERHEATING and/or FIRE and EXPLOSION DURING

STORAGE and/or TRANSPORTATION.

Package each battery to ensure protection of the terminals and avoid electrical short circuit. The following practices are recommended:

Place each battery in sealed individual plastic bag; OR

Use original packaging in which the batteries were received (if in good condition and can be resealed); OR

Place a piece of electrical, i.e., insulating, tape over each terminal to avoid terminal contact.

Based on the high-energy density and reactivity of this

battery category, containers of reactive metal batteries

are limited to a maximum size of 5-gallons (66 lb gross

weight per container).


one of the following DOT specification packages. PG II

performance level spec packaging required.

1A2 – 5-gallon steel, removable head drum with a

minimum 4-mil thickness poly liner; or

1H2 – 5-gallon plastic, removable head drum; or

1G2 – 5-gallon fiberboard drum with poly liner (4 mil

thickness).

Provide cushioning for each battery to prevent contact with other batteries by layering with vermiculite, speedi-dry or kitty litter. Failure to provide adequate cushioning may lead to a fire or explosion during storage and/or transportation!

Apply Universal Waste and Dangerous

#9 label to each pail, drum, and/or

pallet

Ship on Standard BOL using the description:

UN3090, Lithium

battery, 9, II (Used

lithium batteries for




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CAT

HW

Lithium Metal (Primary)

& Li-Alloy

[Used in consumer devices such as cameras and calculators (non-rechargeable) in sizes: AA, C, 9-volt, button & coil cell.



















thickness).

Package batteries to prevent movement during shipment.

For example, layer with vermiculite, speedi-dry or kitty

litter for larger batteries. Failure to prevent movement or

Apply Universal Waste and #9 label to

each pail, drum, and/or pallet.


UN3090, Lithium metal

batteries, 9, II

(Used lithium metal

batteries for




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shifting of batteries may lead to a fire or explosion during

storage and/or transportation!


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4 Li-Ion & Li-Poly

(Secondary)

Li-Ion or Li-Poly batteries are

rechargeable and commonly used in consumer electronics, e.g.,

laptops.]

Fully Recessed Terminals Below








*Lithium-Ion Battery Packs with fully recessed terminals do

not need to be taped or bagged if packaged with other

fully recessed Lithium-Ion Battery Packs.




1A2 – 5-gallon or 55-gallon steel, removable head

drum with a minimum 4-mil thickness poly liner; or

1H2 – 5-gallon or 55-gallon plastic, removable head

drum; or


thickness).

Package batteries to prevent movement during shipment. For

example, layer with vermiculite, speedi-dry or kitty litter for

larger batteries. Failure to prevent movement or shifting of

batteries may lead to a fire or explosion during storage and/or

transportation!

Apply Universal Waste and #9 label to

each pail, drum, and/or pallet.


UN3090, Lithium ion

batteries, 9, II

(Used lithium ion

polymer batteries for




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Magnesium

Similar to alkaline batteries - used

in consumer devices (non-rechargeable) of varying sizes. Rechargeable versions of this

battery type have been examined but are not believed to be

commercially available.



















thickness).

Package batteries to prevent movement during

shipment. For example, layer with vermiculite, speedi-

dry or kitty litter for larger batteries. Failure to prevent

Apply Universal Waste label to each

pail, drum, and/or pallet.



n.o.s. (Used

magnesium batteries

for recycling)


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movement or shifting of batteries may lead to a fire or

explosion during storage and/or transportation!


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Sodium Nickel Chloride

[Used in industrial and/or military applications requiring high power density, e.g., weapon systems and possible applications in electrical

vehicles (rechargeable).]



















thickness).

Package batteries to prevent movement during

shipment. For example, layer with vermiculite, speedi-

dry or kitty litter for larger batteries. Failure to prevent

movement or shifting of batteries may lead to a fire or

explosion during storage and/or transportation!

Apply Universal Waste and

Dangerous #4 label to each pail,

drum, and/or pallet


UN3292, Batteries,

containing sodium,

4.3, II

(Used sodium

batteries for recycling)(ERG

#138)



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Incidental Damaged

Lithium UW Batteries




Package each battery to ensure protection of the terminals and avoid electrical short circuit.

Place each battery in a sealed individual plastic bag;

Package in a separate 1H2 5-Gallon container (Plastic, removable head drum/pail) for damaged batteries










Apply Universal Waste and Dangerous

#9 label to each pail, drum, and/or

pallet


UN3090, Lithium

battery, 9, II

(Used/Damaged

lithium batteries for




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Incidental Damaged

Sodium Nickel Chloride

UW Batteries
















Apply Universal Waste and

Dangerous #4 label to each pail,

drum, and/or pallet

Ship on BOL with other UW batteries under separate line item BOL using the description:

UN3292, Batteries,

containing sodium,

4.3, II (Used/Damaged

sodium batteries for




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Incidental Damaged

Magnesium

UW Batteries
















Apply Universal Waste label to each

pail, drum, and/or pallet

Ship on BOL with other UW batteries under separate line item BOL using the

description:


n.o.s. (Used/Damaged

magnesium batteries

for recycling)


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4.0 Hazards & Risks

Hazard Mitigation 4.1 Foot Injury may occur when a heavy

object, such as a car battery is dropped.

Use of steel-toe safety shoes is necessary to minimize the chance of injury from such incidents. Use safe work habits to prevent possible injuries from occurring.

4.2 Eye Injury may occur during handling of wet cell batteries.

Always wear company issued safety glasses that meet ANSI standards. NOTE: Some batteries contain corrosive liquids – splash goggles and apron should be worn when managing unsealed-type wet-cell batteries.

4.3 Lifting Hazards may be found in repetitive motion associated with loading and unloading of pallets or drums.

Employ proper lifting techniques to avoid injury to the back.

4.4 Acids and Caustics are found in specific UW batteries. Some batteries, most notably lead acid and nickel cadmium, can contain free liquid corrosives (sulfuric acid in lead acid and potassium hydroxide in nickel cadmium). This electrolyte, i.e., battery fluid, is very corrosive and will burn eyes and skin if spilled out of the battery.

Proper care must be taken in handling batteries. During any battery sorting, proper PPE including nitrile gloves, splash goggles and splash apron must be worn when managing such unsealed-type wet-cell batteries.

4.5 Fire Hazard is associated with the storage of Reactive Batteries. Most notably, Lithium batteries can overheat and cause fire when terminals make contact for long periods of time.

Ensure all Category 1 and Category 4 batteries are properly insulated and packaged according to these instructions at all times

Battery Sorting & Handling Work Instructions

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